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Nélio Weiss Philippe Jeffrey Following the publication of the Federal Decree 5922 on October 4 2006, the tax treaty for the avoidance of double taxation and the prevention of fiscal evasion concluded between Brazil and South Africa has entered into force. The provisions of the treaty will apply as of January 1 2007.

Andres Edelstein Gustavo Wunder In 2002 important changes were introduced in the Argentine personal assets tax law. As a result of this reform, it was assumed that the shares and/or participation in the capital of local companies whose owners are companies or other foreign-based legal entities ultimately belong to individuals or undivided estates located abroad.

Anton Hume and Gerlinde Seinsche of BDO examine what possible changes to the UK's and Germany's CFC provisions because of the Cadbury Schweppes case could mean for taxpayers in both countries

Article 15 of the Agreement between the European Community and the Swiss Confederation (the Agreement), which set out measures equivalent to those laid down in Council Directive 2003/48/EC, provided for the application of the principles of Council Directive 2003/49/EC on a common system of taxation applicable to interest and royalties, and the principles of the Parent–Subsidiary Directive, to Switzerland. However, regarding Spain, those measures were not applicable until both countries reached a bilateral agreement on the exchange of information.

Talk of reform is in the air in the US and the UK. But what to do and where to start? At an event hosted by International Tax Review and RSM, a distinguished panel of taxpayers, regulators and advisers, along with an invited audience, debated the issues in London in September

Hans Olav Hemnes Several rumours about changes in the tax system flourished before the red-green coalition presented their budget proposal for 2007. The rumours were especially strong regarding changes in the exempt method for dividend and capital gains in limited liability companies, and the possibility for individual shareholders to extract paid-in capital before taxable dividends in limited liability companies. However, the budget proposal contained no fundamental changes in the present tax system, that is, the tax reform introduced from 2004.

Neil Wilson The Australian Taxation Office (ATO) has issued Practice Statement Law Administration PS LA 2006/10 setting out the factors that will apply when the Commissioner exercises his discretion to vary foreign resident withholding amounts.

International Tax Review's first Americas Awards got off to a strong start in late September. The ceremony was held at the Waldorf Astoria hotel in New York and more than 120 top tax professionals were in attendance to celebrate tax excellence

The German government has published its plans for real estate investment trusts. The Bill compares favourably to similar structures in other countries, reveals Martin Buenning of Allen & Overy

The rules on preferred tax regimes need to change if local companies are to compete fairly with their international counterparts, believe Fred Barrett of PricewaterhouseCoopers and Timothy Cottrell of CEMEX